India’s over-the-counter (OTC) derivatives market is set for a big change — but not immediately.
The Reserve Bank of India (RBI) has postponed the rollout of the Unique Transaction Identifier (UTI) requirement to January 1, 2027.
The earlier deadline was April 1, but it has now been pushed back by nine months.
The reason? Market participants asked for more time to upgrade their systems and reporting processes.
What Is Changing in 2027?
From January 1, 2027, all new OTC derivative transactions in India will require a Unique Transaction Identifier (UTI).
This will apply to transactions such as:
Rupee interest rate derivatives
Forward contracts in government securities
Foreign currency derivatives
Foreign currency interest rate derivatives
Credit derivatives
Currently, these trades are reported to the Trade Repository managed by the Clearing Corporation of India (CCIL-TR).
Under the new rules, every eligible trade entered on or after January 1, 2027, must carry a UTI.
Importantly, the rule will apply only to future contracts.
Existing contracts will not be affected.
Who Will Generate the UTI?
The RBI has clearly defined the responsibility for generating the UTI.
The order of responsibility will be:
The central counterparty (if applicable)
Electronic trading platforms
Clearing members
Any entity mutually agreed upon by both parties
If a trade is reported without a UTI, CCIL-TR will generate one.
However, third-party vendors cannot generate UTIs using their own Legal Entity Identifier (LEI).
This restriction ensures tighter control and accountability.
More Flexibility for Cross-Border Trades
For cross-border transactions that must be reported in multiple countries, the RBI has allowed some flexibility.
If a foreign country has an earlier reporting deadline, Indian market participants must make reasonable efforts to comply.
The deadline to submit the final UTI has also been relaxed. Instead of two business days, entities now have five business days from the trade date.
Temporary or interim UTIs can also be used if the final identifier is not immediately available.
When Is a New UTI Required?
Routine changes to an existing derivative contract will not require a new UTI.
But if a contract is completely replaced with a new one between the same parties, a fresh UTI must be generated.
The Clearing Corporation of India will soon issue detailed operating guidelines and revised reporting formats to help participants prepare.
Why This Matters
The introduction of UTIs is aimed at improving transparency, tracking, and risk management in India’s OTC derivatives market.
By delaying the rollout to 2027, the RBI is giving banks, financial institutions, and market participants enough time to prepare properly.
For the market, this means stronger reporting standards — but with a more practical timeline for compliance.
